On September 5, the American Academy of Family Physicians submitted a 92-page response to the Centers for Medicare and Medicaid Services (CMS) relative to the proposed Medicaid Payment rules released back in July.
The comment letter is comprehensive and seeks to make constructive suggestions on a proposal that the AAFP views as directionally appropriate, but technically flawed and as a net negative for most family medicine practices.
The letter reiterates points made in ongoing conversations with CMS officials. The AAFP has been having productive discussions with CMS over the past 60 days regarding concerns and ways they might be addressed.
- Immediately implement proposed changes in documentation, but delay collapsing payment for CPT codes 99202-99205 and 99212-99215 into a single payment
- Delay implementation of any changes to evaluation and management (E/M) policies or codes and their descriptions until the AAFP and others can help CMS create new ones with values that spur comprehensive, continuous, and coordinated primary care
- Replace the primary care add-on code with a 15% pay increase for E/M services provided by physicians who list their primary practice designation as family medicine, internal medicine, pediatrics, or geriatrics
- Discard the proposed 50% multiple procedure payment reduction for the primary care physicians listed above
- Work with Congress to eliminate deductible and co-insurance requirements for chronic care management codes to foster greater utilization of the codes and improve care coordination for high-need patients; the AAFP also urged a reduction in documentation requirements for these codes.